Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 - Government publications |
From inside the book
Results 1-5 of 52
Page 1
... refund for that year . R issued to Ps a final notice of determination in which he determined that Ps were not entitled to challenge the amount of their tax liability in the administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) ...
... refund for that year . R issued to Ps a final notice of determination in which he determined that Ps were not entitled to challenge the amount of their tax liability in the administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) ...
Page 3
... refund for that year ; and ( 2 ) in any event , the parties should explore alternatives to the proposed levy including an installment agreement , an offer in compromise , posting a bond , or substitution of other assets . On July 2 ...
... refund for that year ; and ( 2 ) in any event , the parties should explore alternatives to the proposed levy including an installment agreement , an offer in compromise , posting a bond , or substitution of other assets . On July 2 ...
Page 4
... refund of $ 519,087 . On October 28 , 2002 , petitioners filed with the Court a Petition for Lien or Levy Action Under Section 6320 and / or 6330.2 The sole issue raised in the petition is a challenge to the amount of petitioners ...
... refund of $ 519,087 . On October 28 , 2002 , petitioners filed with the Court a Petition for Lien or Levy Action Under Section 6320 and / or 6330.2 The sole issue raised in the petition is a challenge to the amount of petitioners ...
Page 19
... refund of $ 519,087 , on Octo- ber 11 , 2002 . Taxpayers who assert that they intend to file an amended return for the first time in connection with a hearing under section 6320 or 6330 should not take solace from the majority opinion ...
... refund of $ 519,087 , on Octo- ber 11 , 2002 . Taxpayers who assert that they intend to file an amended return for the first time in connection with a hearing under section 6320 or 6330 should not take solace from the majority opinion ...
Page 20
... refund of $ 519,087 , I do not interpret the majority as implying that we have the authority to order a refund if petitioners establish that they have overpaid their 2000 taxes . Our jurisdiction under section 6330 is limited to decid ...
... refund of $ 519,087 , I do not interpret the majority as implying that we have the authority to order a refund if petitioners establish that they have overpaid their 2000 taxes . Our jurisdiction under section 6330 is limited to decid ...
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abuse of discretion administrative costs affd allocable to medical amended amortization Appeals Office apply assessed bankruptcy basis carryback challenge Charles Schwab Corp claimed Commis Commissioner Commissioner's Congress corporation Court of Appeals customer accounts decision election entitled Federal income tax franchise tax Grigoraci Income Tax Regs income tax return intangible assets Interest Interest Internal Revenue Internal Revenue Code Internal Revenue Service issue judicial review jurisdiction legislative history levy loss deductions ment monthly service fees noncontract patient fees notice of deficiency notice of determination offer in compromise overpayment interest paid parties payment percentage method peti petition petitioner petitioner's expert procedures proceeding provides pursuant qualified offer refund relief from joint relief under section respect Respondent argues Rose's Rule sioner statutory summary judgment supra T.C. Memo Tax Court tax lien taxable taxpayer tion trial de novo underlying tax liability valuation Village West Wiwi